Académique Documents
Professionnel Documents
Culture Documents
57 Additional Resources
58 Resources for Help
59 Waivers and Amendments
We are a company of passionate over achievers, and we always have been. It’s one reason we’ve
survived and thrived in an industry defined by change.
But another reason is because we are equally passionate about how we do our work. We act with
integrity and in accordance with the letter and spirit of the law. We strive to make sound and ethical
choices that serve our customers, improve our communities, and inspire our team members.
Our Code of Conduct is effectively the global how-to guide for doing business at Dell Technologies,
and it is incumbent on all of us — all roles, all levels and everywhere we operate—to know it and live
it every day. Our leaders have a special responsibility to lead with integrity and in ways that protect
and enhance the reputation of our team and our company.
At Dell Technologies, integrity is not optional. It’s who we are. Thank you for following our Code, living
our values, and fulfilling our purpose.
Michael Dell
Chairman and CEO
Our Code is a global Code. Dell Technologies is based in the United States and thus must adhere to
all laws applicable to U.S. based corporations. We proudly employ team members and serve customers all
over the world. As a result, we must comply with both U.S. laws and the laws of all other countries
where we do business. In those rare circumstances where it appears that local law may conflict with
U.S. law, contact the Legal Department or Global Ethics & Compliance for guidance.
Our Code sets one consistent global standard. While we respect cultural differences, if a local
custom or business practice violates our Code, we must follow the Code. At the same time, if
something permitted or required by our Code violates local law, we must follow local law. Ultimately
we all adhere to one global standard: we win with integrity!
If you have an ethics concern or suspect that someone is behaving illegally or unethically, please speak
Resources :
up. Talk to your leader, call the Ethics Helpline, submit an online report via the web-based Ethicsline, • Ethics Helpline (web or phone)
send an email to ethics@dell.com or use any of the other resources and reporting avenues described
• Global Ethics & Compliance site
in the Code or on the Global Ethics & Compliance intranet site. Dell Technologies does not tolerate
retaliation against anyone who initiates or participates in the ethics process, asks questions or raises
concerns in good faith. Team members and leaders are required to cooperate and be truthful in company
investigations and follow the instruction of the Legal Department, Human Resources and Global Ethics
& Compliance during such investigations.
If you have questions about any topic in the Code, talk to your leader or contact Human Resources, the
Legal Department or Global Ethics & Compliance.
To supplement the general guidance of the Code, Dell Technologies has adopted more specific policies
and standards that apply globally, geographically or to specific business units, functions or departments.
These policies and standards can be found on the Global Ethics & Compliance intranet site.
We believe that what we expect from our people, how we support them in achieving it and how we
measure and reward them for doing so is fundamental to our success and the longevity of our culture.
Our values reflect what’s most important to us as a company and guide our decisions and actions. Our
values, which we call Culture Code, are :
Customers : We believe our customer relationships are the ultimate differentiator and the foundation
for our success.
Winning Together : We believe in and value our people. We perform better, are smarter, and have
more fun working as a team than as individuals.
Innovation : We believe our ability to innovate and cultivate breakthrough thinking is an engine for
growth, success, and progress.
Integrity : We believe integrity must always govern our fierce desire to win.
Our customers and broader stakeholders are the reasons we exist and
they rely on us to listen and provide solutions that will help them succeed.
They expect us to operate with the highest ethical standards. To earn and
maintain their trust, we are committed to doing business fairly, honestly,
legally and ethically wherever we operate in the world.
We Protect the Privacy of
Customer Personal Information
Virtually every country regulates the collection, use, storage, disclosure, deletion and international
movement of personal information. When accessing or handling personal information, we must Key takeaway :
comply with applicable laws and regulations, contractual obligations, the Dell Technologies Code
policies and voluntarily-adopted standards for protecting individuals’ personal information. We must protect and be intentional and
careful about the collection, access and
Personal Information Defined : Personal information includes general information about an individual disclosure of any customer personal
such as name, home address, email and IP address and other contact details. It also includes more
information we handle.
sensitive personal information that may be subject to additional specialized legal or contractual
obligations such as financial records, government issued identification numbers, credit scores,
credit card numbers, medical records, educational or employment records, sexual orientation,
race, family status and political or religious affiliations.
Resources :
Be Intentional and Careful with Personal Information : We use only responsible and lawful
• Global Data Privacy Policy
means to access, collect, use, share, transfer or store the personal information of others, and
use personal information solely for legitimate business purposes. • DellEMC’s Partner Code of Conduct
If your role requires you to have access to personal information, make sure you take steps to properly
protect it and ensure that your access or use is authorized by Dell Technologies.
We give clear notice to individuals of how we will use their personal information, and we respect
customers’ and prospective customers’ communication preferences. We keep personal information
secure in accordance with Dell Technologies security requirements. Additional specific safeguards
apply to customers’ payment card and other financial information.
Collecting, Using and Sharing Personal Information : Do not collect, use, access or share personal
information except as necessary for your job and the jobs of those with whom you share information.
If you or your team initiate an activity where personal information will be collected, consult with the
privacy manager supporting your area of the business or privacy@dell.com to determine whether a
privacy impact or security assessment is necessary. If you transfer personal information from one
country to another, even to share with a colleague or third party in another country, make sure the
transfer is an approved part of your job.
(Continued)
How We Win: Dell Technologies Code of Conduct 11 Customer
(Continued)
We must respect individuals’ interests in their own personal information. Should you get an inquiry
from an individual regarding information we hold on that person, you should handle that request in
accordance with Dell Technologies policy. If you have any questions in regard to such policy, forward
your inquiry to the Privacy team at privacy@dell.com.
Third Parties : Our business partners must share our commitment to protecting and appropriately
using personal information. Before sharing personal information with any business partner, be sure
the partner has executed the appropriate contracts, memorializing their commitment to following
the law and adhering to Dell Technologies’ policies and standards. For more information regarding
working with our channel partners, see DellEMC’s Partner Code of Conduct provisions on protecting
and securing customer and team member personal information.
Q&A :
Q : W
e have a great new product we know is going to be a big hit and want to tell people about it. We
have engaged a marketing vendor who has a list of email addresses of prospective customers.
Can we use the list for our marketing campaign to get the word out?
A : M
aybe. It depends on the applicable legal requirements. Most countries have rules about whether
and how email addresses can be collected, whether and what type of consent is needed from
customers to receive email and when and how you can use emails for marketing purposes. Reach
out to the Legal Department or Privacy team for guidance at privacy@dell.com.
If you have questions or concerns about the safety, security or compliance of a Dell Technologies
product, contact the Product Compliance Team at product_compliance@dell.com.
Competition laws are complex. Always consult with your manager and the Legal Department before
entering into any discussions with competitors, customers, resellers or suppliers about agreements
or arrangements, whether in writing, oral or implied, that could have the effect of limiting competition
or that could be perceived as having such an effect.
Q&A :
Q : A systems integrator (SI) placed an order for 50 desktops for an end user. The order has been
approved and downloaded and is in the process of being shipped. The SI just contacted me and
said he is concerned his customer might not be able to pay. I don’t want to cancel the order so I
told him I would help him find other buyers for the systems if that happens. Is this OK?
A : N
o, not unless you negotiate a formal amendment to the original order and obtain all the necessary
approvals from Legal, Finance and Accounting. If you fail to take these steps, your oral agreement
is an impermissible “side letter” or “unauthorized commitment” and it changes the terms of the
original order which could affect when the company is able to recognize the revenue from the sale.
Q&A :
Q : I noticed that one of our subcontractors billed a government customer for a USD $10,000 server
that was not part of their order. Could this be fraud? Should I just let the subcontractor worry
about it?
A : While this may or may not constitute fraud, you must not ignore suspicious activity relating
to government contracts. Report the matter immediately using any of available internal
reporting avenues.
All team members are expected to report suspected harassing conduct promptly and never retaliate
against anyone who raises a good faith concern that unlawful harassment has occurred.
Resources :
• EICC Code of Conduct
You must report all accidents, injuries, unsafe work conditions, releases to the environment
and other EHS concerns immediately to your supervisor, and to others as described in the
applicable procedures. Resources :
If you hire and/or procure contractor or business partner work, you must ensure that each contractor
• Global Workplace, Environment &
and partner has an EHS program appropriate to the type of work to be performed, is made aware Facilities site
of other potential hazards in the work area, and follows Dell Technologies’ contractor safety and
environmental requirements. If you work at customer or supplier/partner locations, you must follow
the stricter of Dell Technologies’ or the customer or supplier/partner’s EHS requirements.
Q : How can my team learn about the EHS requirements that apply to my workplace?
A : Refer to the Global Workplace, Environment & Facilities site referenced in the
Resources of this section.
Q : I install and service equipment at customer facilities. Do I follow Dell Technologies’
or the customer’s safety rules?
A : Both. Dell Technologies requires you to follow the stricter of each requirement.
Q : My leader has suggested adopting a practice that will save time but poses a potential
safety risk. What should I do?
A : Never compromise your safety or the safety of your team members or others. Report
the matter to another leader or use the other available reporting avenues.
Q&A :
Q : Can I bring my own gun to work if I have a license or concealed permit?
A : No. Dell Technologies policy prohibits the carrying of firearms in Dell Technologies
buildings or while conducting Dell Technologies business.
As innovators we strive to think and create beyond our limits and work
with others to better our communities and our planet. We also utilize
innovative tools to create and protect our most valuable ideas.
We Safeguard Our
Confidential Information
Dell Technologies confidential or proprietary information is a tremendously valuable asset that
differentiates us from our competitors and is protected by law and key agreements. Some of this Key takeaway :
information is also considered protectable trade secrets under the law. Everyone is responsible for the
protection of Dell Technologies confidential or proprietary information and trade secrets. Misusing Misusing or disclosing information that
or disclosing information that Dell Technologies considers confidential or proprietary or a trade secret, Dell Technologies considers confidential
whether during or after employment, is prohibited and is a violation of the Code of Conduct and your or proprietary, or a trade secret, whether
agreements. In certain circumstances, it may also be a violation of law. Inappropriate disclosure may during or after your employment, is
also result in serious consequences to you and Dell Technologies. Before you disclose or distribute prohibited and is a violation of the Code
any confidential information, senior management approval must be obtained and the appropriate terms of Conduct and your agreements with
of use established. This often requires the execution of a written confidentiality or nondisclosure Dell Technologies.
agreement, which restricts the use, disclosure or distribution of the information.
(Continued)
All Dell Technologies confidential or proprietary information must be returned when you terminate
employment with Dell Technologies. Any taking, downloading, disseminating or other prohibited use
or disclosure of Dell Technologies confidential or proprietary information could constitute theft of
Dell Technologies property. If such Dell Technologies confidential or proprietary information is deemed
a trade secret, additional laws may apply.
Additionally, you must take steps to prevent inadvertent disclosure of Dell Technologies confidential
or proprietary information. All security rules must be followed. In addition, you should not discuss
any non-public or confidential or proprietary information about Dell Technologies with outsiders,
including family and friends, and should not discuss such information in any public place, such as
an elevator, restaurant or airplane. Even within Dell Technologies, information should be shared with
others only on a “need to know” basis. For example, broadcast emails containing Dell Technologies
confidential or proprietary information should be avoided. You should not post any Dell Technologies
confidential or proprietary information when using social media tools such as blogs, internet chat
boards or social networking sites without prior express authorization. When away from Dell
Technologies premises, special care should be taken to protect Dell Technologies confidential or
proprietary information, in both tangible and electronic form, to prevent inadvertent disclosure in
public places.
You are likely to meet, talk to or attend functions with individuals who work for Dell Technologies
competitors, partners, suppliers or customers. When you come into contact with such individuals,
even where the interaction seems innocent, you must be cautious about what you say. You should
never discuss Dell Technologies confidential or proprietary information with competitors and must
be careful to only discuss Dell Technologies confidential or proprietary information with customers,
partners or suppliers in adherence to the Technology Resources and Information Governance Policy
and with a fully executed Non-Disclosure Agreement between Dell Technologies and the other party.
In some cases Dell Technologies has special policies or procedures in connection with its business
relationships that require heightened attention to the safeguarding of Dell Technologies confidential
and proprietary information.
You should also report any attempts by outsiders to obtain Dell Technologies confidential or
proprietary information by contacting cybersecurity@dell.com.
Q : I am leaving Dell Technologies. Can I download or copy business documents that I created
while at Dell Technologies? They are mine, right?
A : No. This information belongs to Dell Technologies and may be confidential or proprietary.
Downloading or copying documents when leaving Dell Technologies is a violation of this Code,
your agreements with Dell Technologies and is possibly illegal.
Q : Can I tell my manager or co-workers about a potential acquisition target Dell Technologies
is considering?
A : It depends. To protect the confidentiality of Dell Technologies’ strategic business plans and
ensure we can comply with all applicable legal requirements, Dell Technologies places tight
controls around our acquisition projects. Only certain essential team members are informed
of a potential acquisition and they are subject to strict nondisclosure obligations. Unless you
know your manager or co-worker is already part of the team working on that project, you
should check with the project manager before talking to your manager about it.
Once you have received confidential information through legitimate means, you should use,
copy, disclose, modify and/or distribute it only in accordance with the terms of any relevant
confidentiality or nondisclosure agreement. You must also abide by the lawful obligations you
have to your former employer(s). These obligations may include restrictions on the use and
disclosure of confidential information or solicitation of former colleagues to work at Dell
Technologies, or non-competition agreements.
Resources :
• Cybersecurity S.A.F.E. site
Everyone has an obligation to keep our information technology resources safe from viruses, malicious
software programs and intrusion attempts by following all information security policies and never
tampering with or disabling the Dell Technologies managed security software on a system. You are
responsible for all activity performed with your individually-assigned user ID and your assigned IT
resources. Ensure that all software and hardware purchases and agreements are approved by the
Information Technology Department. If you have access to customer information technology
resources, you should follow policies and procedures relating to the use of information technology
resources and to information security as directed by the customer.
Take care when using instant messaging (IM), texting, weblogs (“blogs”), chat, social media and Resources :
other avenues for electronic or online communication. Dell Technologies supports such open
• Global Social Media Policy
communications, as long as such communications are done legally and ethically. You must adhere
to the Dell Technologies Social Media Policy.
Everything we tell customers and prospective customers about our products and services - in our
advertising, sales and marketing communications or otherwise - must be truthful, accurate,
complete and understandable.
Make sure you comply with all internal requirements relating to the review and approval of advertising
and marketing communication materials. Seek guidance from the Legal Department when you are
unsure or have questions.
Q&A :
Q : A reporter called to ask me some questions on a news story about Dell Technologies
on a topic that I am very familiar with. How should I respond?
A : Unless you have been specifically authorized to speak about the topic on behalf of the
company, you should refer the reporter to Corporate Communications.
Q&A :
Q : How do I get involved in sustainability activities in my location?
A : Join the Planet Employee Resource Group! As one of Dell Technologies’ largest ERGs, Planet
gives team members opportunities to volunteer and get involved in environmental activities
where they live and work.
Q&A :
Q : I believe a team member made a false statement to Dell Technologies’ independent auditor.
What should I do?
A : Report the matter immediately to the Legal Department or Global Ethics & Compliance at
ethics@dell.com. You may also notify Dell Technologies’ Chief Financial Officer at
chief_financial_officer@dell.com or Audit Committee at Board_of_Directors@dell.com.
Any questions related to the above should be directed to the Legal Department.
Q : In support of a government opportunity, a partner is requesting a discount that is above and
beyond what is customary for the given product and market. Is this concerning?
A : Yes. Excess margin, especially in connection with a public deal, is a red flag as it may be a means
for creating a slush fund — a side account maintained for unlawful purposes, such as paying a bribe.
You must take extra precautionary measures in this scenario and consult with Finance or Global
Ethics & Compliance.
Q : A customer wants to place an order that is for the benefit of a military end-user in EMEA. I’m
having difficulty gathering more information about the particular order and cannot confirm who
the end-user is or what they intend to use the product for. What should I do?
A : Speak up! Contact Global Trade Compliance to raise your concern or question. Remember, Dell
Technologies cannot sell to individuals or entities if we know or suspect they will use the Dell
Technologies products, software, services or technologies for certain prohibited end-uses, such
as terrorist activities or the development, design, manufacture or production of rockets/missiles
or nuclear, chemical or biological weapons.
Q : Can we sell products or consulting services to the Iranian embassy in Germany, since it is located
in a non-embargoed country?
A : No. Even if the embargoed entity has a location based in a country that is not embargoed, it is
still prohibited. Selling products, services, software or other solutions are all prohibited, as it
is still a financial transaction between Dell Technologies and an embargoed country, regardless
of what is being purchased. Similarly, if a bank is headquartered in an embargoed country, yet
has a bank branch located elsewhere, we cannot sell to that bank branch in the non-embargoed
location. Any questions should be directed to Global Trade Compliance.
Outside board memberships and governance roles : Dell Technologies team members are not
permitted to serve on the boards of outside for-profit companies, whether publicly traded or private,
with the rare exception that members of Dell Technologies’ Executive Leadership Team and certain
Senior Vice Presidents may request to serve on a for-profit board in strict adherence to Dell
Technologies’ Global Conflicts of Interest Policy and with the approval of Dell Technologies’ Chief
Executive Officer. Service on the board of a non-profit entity is generally permitted but must also
adhere to Dell Technologies’ Global Conflicts of Interest Policy.
Q : I have been asked to participate as a subject-matter expert for a paid research network. Is
that allowed?
A : No. Dell Technologies will not permit current team members to participate in that type of paid
outside engagement, as there is too much opportunity for Dell Technologies confidential information
to pass between parties. To ensure this is avoided, team members wishing to engage in outside
consulting activities should seek permission through Global Ethics & Compliance or the Legal
Department, to ensure that these opportunities are permissible.
Q : Special rules apply when providing gifts and hospitality to government or quasi-governmental
customers also called “Public Customers.” Who is a government or quasi-governmental customer?
A : A “Public Customer” is defined in the Dell Technologies Global Gifts and Hospitality Policy.
Public Customers include employees of the U.S. or another countries’ central, state or
provincial governments, but also may include employees of educational institutions, hospitals
or any other government owned or government funded entity, such as oil companies or airlines.
Q : Where do I submit requests from organizations that want to utilize Dell Technologies and/or
Dell EMC logo?
A : For use of Dell Technologies logos by 3rd parties, please submit all requests to brand@dell.com
Q : Who do I contact to reserve Dell Technologies facilities for hosting an on-site event?
A : You will need to submit for approval to the facilities team for hosting any event on-site. You can
find more information on the Facilities Service Request site.
Dell Technologies does not make corporate political contributions, even when legal to do so. Whenever
you have a question about a Dell Technologies-related public policy or political matter, please contact
your Government Affairs team first.
Q&A :
Q : I have a good friend who is running for political office and has asked if I would endorse him at
a rally being held outside of business hours. Is that a problem?
A : No. Just be sure to make it clear that your endorsement is your own personal action and that
you are not speaking on behalf of Dell Technologies.
Security Office
Security@dell.com
This version of the Dell Technologies Code of Conduct was approved by the Board of Directors
in September 2017.